Introduction On 22 July 2025, the UK Office of Financial Sanctions Implementation (“OFSI”), which is responsible for the enforcement of financial sanctions in the UK, opened a public consultation on proposed amendments to its civil monetary penalty procedures. The consultation (available here) seeks input on five key categories of amendments to OFSI’s current civil enforcement processes as follows: Responding to the consultation The deadline to provide responses to the consultation is 23:59 London time on…
Background The European Union continues to expand its sanctions regime against Russia and Belarus. The latest – the 18th – EU Russia/Belarus sanctions package was published on 19 July 2025, and included a range of additional sanctions, mainly targeting the Russian energy, banking and military industries, but also individuals and the Russian shadow fleet (see our previous blog post on the 18th sanctions package). EU sanctions against Russia are enacted in the form of regulations,…
On 31 July 2025, the UK Office of Financial Sanctions Implementation (“OFSI”) announced that it had imposed a monetary penalty totalling GBP 300,000 on Markom Management Limited (“MML”), a provider of fiduciary, management, administration, bookkeeping and accounting services incorporated in the UK. The monetary penalty related to conduct in 2018 and a breach of the UK’s pre-Brexit sanctions regime, specifically the UK’s implementing regulations for Council Regulation (EU) No 269/2014 (Ukraine Misappropriation and Human Rights)…
Emphasis on protecting US business, economic and national security interests In brief During a May 12 speech and in a newly issued Criminal Division White-Collar Enforcement Plan (the “Plan”), the Head of the US Department of Justice (DOJ)’s Criminal Division, Matthew R. Galeotti, set out the Department’s priorities for corporate criminal enforcement under the new Administration and issued a number of updated policy documents. These changes affect the Criminal Division’s Corporate Enforcement and Voluntary Self-Disclosure…